The Mystery of the Missing Bolts

:
New York City’s Stricken Indian Point Nuclear Plant
A collaboration between Friends of the Earth and Fairewinds Associates, Inc
May 24, 2016
Executive Summary
“Missing bolts” and “nuclear reactor” are words one generally does not want to see in the same
sentence. And when the missing bolts are many, the risk and concern multiply.
In the case of the Indian Point nuclear power plant just outside of New York City, the risk is that
the missing bolts will cause the nuclear reactors to overheat, meltdown and release deadly
radioactivity over the surrounding population and countryside. Specifically, leaks due to the
missing bolts could deprive the reactor of sufficient cooling water to contain the 550 degrees
Fahrenheit temperature in the reactor’s nuclear fuel, triggering an uncontrollable nuclear
meltdown with catastrophic results from temperatures reaching more than 2,000 degrees. More
than one out of every four bolts that help channel cooling water to the Indian Point Unit 2 reactor
is currently damaged or missing, according to an inspection by the plant’s owner Entergy. This is
an extraordinarily high failure rate that appears to be unprecedented in the history of the global
nuclear power industry.
Indian Point reactor Unit 2—and its twin “sister,” Indian Point 3—are located 26 miles north of
New York City, along the east side of the Hudson River. Depending on the speed and direction
of the wind, any radioactivity escaping from Indian Point could easily reach New York’s Times
Square within 90 minutes, making mass evacuation impossible.
This situation demands immediate remedy.
This collaborative report aims to urge and inform a viable solution. It offers recommendations
and specific actions that should be taken by Entergy (the corporate owner of Indian Point) by
state government, and especially by federal regulators, the Nuclear Regulatory Commission
(NRC).

New York Governor Andrew Cuomo, citing a string of previous safety concerns at Indian Point,
has been calling for the plant’s closure since his tenure as the state’s attorney general from 2006
to 2010. At a minimum, the current episode signals for Indian Point Unit 2 to remain off-line
until the Mystery of the Missing Bolts is fully investigated, analyzed and totally corrected, if
correction is even possible. Because Indian Point Unit 3 is, technically speaking, virtually
identical to its sister reactor, Indian Point Unit 3 should also be taken off-line immediately to
undergo a rigorous independent investigation before being allowed to operate again. With 20
million people across three states living within 50 miles of Indian Point, any risk of a nuclear
accident is unconscionable.
To explain why such a strong response is necessary, this collaborative report begins by
describing how the missing bolts were discovered. It notes that some of the bolts in question are
outright missing while others are broken or damaged. The report observes that the 27.2 percent
failure rate of the reactor bolts at Indian Point Unit 2 appears to be unprecedented at a global
scale, and it explains in layperson’s terms why such a widespread absence of bolts poses
extraordinary danger to the reactor and therefore the public.
The Mystery of the Missing Bolts: A Brief History
The missing bolts at Indian Point Unit 2 were discovered in a March 2016 inspection that the
state of New York insisted upon over repeated objections from Entergy.
Entergy took ownership of the Indian Point Unit 2 and Unit 3 reactors in 2001. The plants were
built in the early 1970s by Consolidated Edison, the utility company that distributes electricity to
much of New York City and its northern neighbor, Westchester County. The reactors occupy
what Entergy calls the Indian Point Energy Center, which is located roughly 26 miles from New
York City limits and only 36 miles from midtown Manhattan, along the eastern side of the
Hudson River in the town of Buchanan, New York.
Indian Point Unit 2 and Indian Point Unit 3 are large power plants that generate a sizable amount
of electricity. Historically, the two nuclear reactors have generated around 10 percent of New
York’s power. Indian Point Unit 2 has a generating capacity of 1,032 megawatts (MW); Indian
Point Unit 3, a generating capacity of 1,051 MW.
From their beginning, the Indian Point nuclear reactors have experienced a string of major and

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minor safety problems. Five months after Indian Point Unit 2 opened, it was closed to repair a
faulty containment dome, the structure designed to prevent radioactivity from escaping in the
event of a reactor meltdown. Often as a result of fires, electrical transformers in particular have
malfunctioned at Indian Point, unleashing toxic liquid into the Hudson River. As recently as
2013, a veteran former supervisor at Indian Point was arrested and charged with falsifying safety
reports and lying to federal regulators.
The recurring safety lapses at Indian Point, and the apparent laxness on the part of its owner
Entergy, led state and local officials, environmental organizations and ordinary citizens to
demand better. Andrew Cuomo called Indian Point “a catastrophe waiting to happen” and called
for the plant to be shut down in 2007 while serving as the attorney general of New York. As
governor, Cuomo has continued to urge closure of the entire complex. Meanwhile, the Cuomo
administration continues to closely monitor developments and pushes corporate owner Entergy
and the NRC to be more vigilant.
In particular, the Cuomo administration has demanded a thorough safety inspection before the
NRC rules on whether to allow Indian Point Units 2 and 3 to continue operating past the plants’
original 40-year operating licenses. Those licenses expired in 2013 and 2015, respectively. Like
any industrial facility, a nuclear plant encounters issues as it ages: parts wear out, scientific
advances counsel different approaches to issues such as earthquakes. Challenges of aging are
especially acute for nuclear reactors, because of the extraordinary stresses imposed by the high
temperatures, neutron bombardment, and extreme water pressure inside a reactor.
The Governor pressed the Nuclear Regulatory Commission to require inspections of the baffleformer bolts in the Indian Point reactors. At the insistence of the Governor, Entergy did
undertake inspections commencing on March 7, 2016.
The results of the Indian Point inspection confirmed the Cuomo administration’s fears. Entergy
reported its findings in a March 29 report to the NRC’s Atomic Safety and Licensing Board
Panel, a group of three nuclear specialists who conduct public hearings and rule on the licensing
and operation of US nuclear plants. Entergy declared that its inspectors discovered that 227 of
the bolts that surround the Indian Point Unit 2 reactor were either missing or damaged.
The bolts at issue are critical safety components that go by the awkward name of “baffle-former
assembly bolts.” They hold in place metal plates—baffles—that channel cooling water through
the reactor, providing essential protection against the possibility of over-heating. A quarter of a

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million gallons of cooling water flows through the core of the Indian Point Unit 2 reactor every
minute it operates. The baffles assure that this cooling water enters and leaves the reactor core in
the proper amount, timing and velocity. If enough bolts are missing, the baffles may slip and
these vital safety functions would be interrupted. See figure below.
Figure 1 shows Fairewinds Associates’ Chief Engineer at a full-scale mockup of a
Westinghouse nuclear reactor similar to Indian Point Unit 2. The reactor’s emergency cooling
water, depicted in blue, enters at the upper-left corner. When the baffle bolts and other reactor
internals are functioning properly, the water descends along the outside of the reactor’s “core
barrel” to the base of the reactor. It then moves uniformly upward through the nuclear core,
keeping the core temperature in the safety zone, before exiting the reactor at top right.

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Figure 2 illustrates how missing or damaged baffle bolts can cause the reactor to overheat. If the
bolts fail, the plates will open, allowing the cooling water to deviate from its normally tightly
constrained path through the reactor, risking overheating of the reactor core and an
uncontrollable nuclear reaction and meltdown.

The Indian Point Unit 2 nuclear reactor was designed to rely on a total of 832 baffle-former
assembly bolts. Finding that 227 of these bolts were either missing or damaged meant that 27.2
percent of the reactor’s baffle-former assembly bolts were defective. No other Westinghouse
Pressurized Water Reactor has ever reported even half that failure rate.
Instead, Entergy tried to portray an entirely different situation. Presenting the glass as half-full,
Entergy’s public statement after the inspection declared that only 11 percent of the roughly 2,000

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bolts it had inspected were degraded. Tellingly, Entergy admitted as much in a legal filing it
submitted in parallel with its public statement. With the company’s legal liability on the line, its
officials provided data that was, one can say, more precise. This data revealed that, in regards to
the 832 “baffle-former assembly bolts” around the reactor, 227 were defective. In other words, a
27.2 percent failure rate.
As far as Fairewinds Associates can determine, this failure rate is unprecedented, not only in US
reactors but globally. Not surprisingly, it also appears to violate the safety standards prescribed
by the reactor’s manufacturer, Westinghouse.
Westinghouse’s guidance is worthy of attention. No company has a longer, deeper history in the
nuclear industry than Westinghouse. In 1946, the US Navy chose Westinghouse to design and
build the first reactor intended for electric generation rather than strictly military purposes; the
company went on to sell more reactors, in more countries, than any other nuclear corporation.
After the market for new reactors crashed in the 1970s, Westinghouse focused on servicing the
existing reactor fleet—providing refueling, maintenance and repairs. Westinghouse shares
Entergy’s confidence that reactors and power plants originally designed to operate for 40 years
can safely soldier on for decades into the future.
But aging is a reality that cannot be ignored, and Westinghouse appropriately cautions that as
reactors age, attentive monitoring and careful maintenance are essential to assure proper
standards of safety, efficiency and output. In a technical manual published in October 2014,
Westinghouse explicitly addressed, among other issues, the role of baffle-former assembly bolts,
which it called “a critical safety feature”: “One component that is critical to maintaining the
structural integrity of the internals [of the reactor], and that has been shown operationally to be
susceptible to aging mechanisms, is the baffle-former assembly bolts.” The main concern, the
manual added, is that radiation from the reactor can lead to “corrosion” and “cracking” of the
bolts.
Westinghouse further claimed that a “failure of a few bolts should not have a significant safety
impact,” because redundancy in the reactor design would keep enough bolts in place to assure
safe operations. But even if one accepts this less than air-tight standard, the situation at Indian
Point Unit 2 falls well short. What has failed at Indian Point Unit 2 is emphatically not just “a
few bolts. It is one out of every four.

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Most automobile drivers wouldn’t get behind the wheel if they knew that one out of four bolts
holding their car together was missing or broken. Why should a weaker standard apply for a
nuclear reactor?
Which raises the questions, how did this happen and why was it not caught sooner? Indian Point
has a “loose parts monitoring system” that is designed to detect metal bouncing within the
reactor. The facts suggest that this early warning system also failed, because either there was no
warning of damage or it was not reported.
What risks do the 227 missing or broken bolts present?
1. Broken pieces of metal can damage the nuclear fuel, causing it to leak and release
radiation onto the surrounding environment and community, perhaps necessitating an
evacuation.
2. Such metal fragments can damage the reactor’s control rods, making it difficult or
impossible to shut down the reactor.
3. This “floating shrapnel” can clog a fuel channel, causing the nuclear fuel to overheat,
raising the potential of a meltdown.
4. The floating shrapnel can damage the impeller of the reactor coolant pumps, causing
them to vibrate and develop dangerous oscillations in reactor coolant flow.
5. The 227 missing or damaged bolts could cause the baffle plates that channel cooling
water into the reactor to loosen and fail, thus preventing sufficient water from reaching
the reactor core, again raising the possibility of a meltdown.
How can this situation possibly be considered safe? How long has Indian Point Unit 2 been
operating this way, and how can anyone be assured that it won’t happen again? Is there a way to
repair the reactor that can assure there will not be further, more rapid, deterioration of the
remaining baffle-former bolts?
If Entergy can answer these questions persuasively, a restart of Indian Point Unit 2 might be
appropriate. The plant should remain off-line until the root cause is determined, and there is
assurance that the repairs are effective indefinitely and the defect will not reoccur. Without a full
understanding of the root cause of bolt degradation, there can be no assurance that the remaining
old bolts will not fail, nor that failure of replacement bolts will not occur. What’s more, since
Indian Point Unit 3 is virtually the same design and only two years younger than its sister, it
should undergo the same rigorous inspection to determine whether it too has a missing or

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damaged bolt problem.
The NRC Must Order A Root Cause Analysis
The Nuclear Regulatory Commission is mandated by the Atomic Energy Act and its own
regulations to assure the safe operability of all operating reactors in the US. The unprecedented
degradation of the baffle-former bolts at Indian Point 2 poses a significantly increased risk to the
safe operation of a nuclear reactor located within relatively short distances of tens of millions of
Americans. Moreover, the discovery at Indian Point 2 that a quarter of the baffle-former bolts are
damaged or missing raises a serious question about the potential safety of the nation’s fleet of
Westinghouse Pressurized Water Reactors.
Both these reasons demand that the NRC step in to assure the public of the safety of the
Westinghouse nuclear reactors across the country. We therefore urge the NRC to follow
established procedures and dispatch an independent Augmented Inspection Team (AIT) that can
thoroughly investigate the situation inside both Indian Point Unit 2 and Indian Point Unit 3 and
propose appropriate remedies. Meanwhile, the NRC should issue a Confirmatory Action Letters
(CAL) requiring Indian Point Unit 2 to remain closed until the root cause of the failures in its
reactor safety equipment is understood and a complete repair is completed; and a second CAL
ordering the immediate shutdown of Indian Point Unit 3 for its own in-depth inspection. Until
the ultimate root cause of any problem is determined at either Unit 2 or Unit 3, it is impossible to
determine what may be an effective remedy, if one can even be determined and implemented.
The failure of baffle-former assembly bolts is not a new problem for the nuclear industry. The
problem has been recognized since the late 1980s, as NRC Information Notice 98-11 reported in
March 25, 1998:
European plants identified the cracking of baffle former bolts as early as 1988
and this problem continues to occur. Although this cracking is not fully
understood, testing of cracked bolts suggests an age-related intergranular stresscorrosion cracking process influenced by bolt material, fluence, stress, and
temperature. 1 (emphasis added)
As worrisome as the absence of critical safety bolts at Indian Point Unit 2 is, also unsettling is

that no one yet knows why so many bolts failed. Normal wear and tear from aging is certainly
plausible, but is far from the only possible explanation. Other possible causes include:
1. Improper initial torque: appropriate pressure was not applied to the wrenches when the bolts
were installed.
1.1. Thermal expansion differences between the bolt and the threaded hole it is inserted into
could have reduced the torque on the bolt.
2. If this is a more recent event, the bolts could have failed due to:
2.1. Fatigue of the bolt head from vibration due to years of exposure to rapidly flowing
water.
2.2. Damage to the bolt by the phenomena of neutron embrittlement, a metal deterioration
created by the proximity of the metal to the reactor core and constant bombardment by
neutrons as the reactor fuel is fissioning 2.
If and when nuclear reactors experience a missing bolts problem, Westinghouse recommends
undertaking an engineering analysis that the company calls “Acceptable Baffle-former Bolt
Pattern Analysis,” or ABPA. Westinghouse goes so far as to assert that, with the assistance of an
ABPA, a reactor can operate safely “even with many non-functional bolts.” Dubious as that
claim may sound to non-Westinghouse experts, including Fairewinds Associates, ABPA does
enable investigators to determine the safety significance of missing bolts and to assess what
remedial measures might restore acceptable safety levels. Before restart is permitted, this report
should be made publicly available for independent assessment.
To conduct an ABPA investigation requires data and information that Entergy and the NRC,
unfortunately, either have not obtained or have withheld from independent experts. This
information includes, but is not limited to, the following:
1. A map of the distribution of the 227 missing or failed bolts.
2. Photographs of the failed and missing bolts and the threaded holes into which they were
inserted so they may be analyzed for the type of damage as well as location.
3. Neutron fluence data on each missing bolt.
4. Metallurgical data on how the bolts were manufactured.
2

Fission – “The splitting of an atom, which releases a considerable amount of energy (usually in the form of heat)
that can be used to produce electricity. Fission may be spontaneous, but is usually caused by the nucleus of an atom
becoming unstable (or "heavy") after capturing or absorbing a neutron. During fission, the heavy nucleus splits into
roughly equal parts, producing the nuclei of at least two lighter elements. In addition to energy, this reaction usually
releases gamma radiation and two or more daughter neutrons.” http://www.nrc.gov/reading-rm/basicref/glossary/fission-fissioning.html

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5. Video and reports from prior inspections that may reveal whether the component and
structural failures were evident earlier.
6. Data on the bolts still in place, which might reveal why these bolts have not failed—or
detect failures in the offing.
7. The extent/nature of the degradation of the 227 baffle-former bolts on IP Unit 2.
8. Whether or not there are loose parts in the reactor and, if so, why the Metal Impact
Monitoring System did not detect those parts.
9. If the Metal Impact Monitoring System failed, what kind of technology-based systems
and/or mechanical and structural components must be investigated, tested, and analyzed.
10. Whether all missing bolt pieces will be recovered prior to the restart of the reactor(s) and
evaluated.
11. The number of degraded bolts that can be tolerated from a safety related engineering
viewpoint before the integrity of the baffle-former assembly is compromised.
12. Whether some reviewers and assessors are correct that the excessive cooldown of the
reactor coolant system during the February 2000 steam generator tube leak at IP Unit 2
may explain why so many baffle bolts suddenly degraded.
Entergy Has A Pattern Of Scrimping On Safety
The magnitude, complexity, and seriousness of these missing and broken baffle-former assembly
bolts calls for undertaking a root cause analysis of the problem. Instead, Entergy appears to be
rushing through its repairs in order to bring Indian Point Unit 2 back into operation in time for
the financially lucrative summer season, when electricity demand peaks between June and
October. Only the NRC can force Entergy to slow down and spend the time and money required
to truly understand and appropriately respond to this situation.
Beyond the obvious motivation of limiting costs and maximizing revenue, Entergy’s lack of
enthusiasm for investigating the missing bolts mystery at Indian Point may reflect the company’s
historical approach to reactor safety. On more than one occasion, Entergy has balked at
undertaking rigorous inspections of its nuclear plants. This has led, directly or indirectly, to
serious mechanical problems as well as public safety risks. Here are two particularly salient
examples:

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Vermont Yankee
The “Vermont Yankee Oversight Panel,” a team of experts picked by Vermont’s
Governor and legislature, investigated Entergy’s reliability to operate the Vermont
Yankee nuclear power plant for 20 additional years beyond its original license period.
The panel’s report, issued in 2010, noted that Entergy was not spending enough money
maintaining the Advanced Off-gas System (AOG) at Vermont Yankee, a failure that
resulted in radioactive cesium and cobalt leaking into the ground water and the
Connecticut River. The Panel further warned that insufficient safety spending by Entergy
probably contributed to a fire in 2004, the collapse of a cooling tower at Vermont Yankee
in 2007, and to groundwater leakage of radioactive cesium, strontium and cobalt in 2008.
The Panel concluded that, “ENVY [Entergy Nuclear Vermont Yankee] management
needs to assure adequate resources are allocated to the reliability of non-safety-related
systems.” 3
Arkansas Nuclear One
In 2014, workers at the Arkansas Nuclear 1 power plant inadvertently dropped a
generator rotor weighing hundreds of tons, killing one employee and injuring several
others. According to published reports one of the causes of this fatality was inadequate
financial resources provided by Entergy: “ ‘Entergy Corp. made cutbacks across its fleet
of nuclear power plants from 2007 through 2013 to try to remain competitive,’ said Neil
O'Keefe, the [NRC] branch chief responsible for oversight of Arkansas Nuclear 1…. ‘It is
clear that our performance experienced subtle decline from 2007 to 2013,’ said Jeremy
Browning, site vice president over the plant. As a result of that subtle decline, selfrevealing events occurred at this [plant], resulting in a need for the NRC to intervene." 4
Entergy is hardly unique in pursuing “quick and easy” fixes rather than the more time-consuming
and costly approach of tracing evidence as far back as necessary to determine the root cause of a
problem. This tendency exists to greater or lesser extents throughout the nuclear industry. The
industry’s history is replete with inadequate “fixes” of serious failures because reactor owners

jumped to conclusions in order to find quick, cheap fixes. Doing so did not solve the original
problems, however; often, it exacerbated them.
As a result, the NRC has repeatedly failed to adequately protect public health and safety during
and after major equipment failures at other reactors across the country. Three examples follow.
NRC’s Past Failure to Intervene Has Worsened Nuclear Plant Issues
In the past, the NRC has too often taken the same kind of “hands-off” approach to nuclear plant
safety that it has so far at Indian Point, with unfortunate results.
Quad Cities
The Quad Cities nuclear reactor, located near Cordova, Illinois, experienced severe
cracking of its steam dryer in 2002. The steam dryer is a key component inside a nuclear
reactor; placed directly above the core, its function is to remove moisture from the steam
that powers the generator to create electricity. Both the owner of the plant, [Exelon], and
the reactor designer, [General Electric], believed that they understood the cracking
problem, and that they had made appropriate repairs. The NRC reviewed the companies’
calculations, did no investigation of its own, and ruled that the reactor could be restarted.
One year later, the steam dryer cracked again. Again, it was repaired and restarted, only
to fail a second time.
Millstone Unit 1
During a refueling outage in 1973 at Millstone Unit 1, a nuclear plant located in
Connecticut, visual inspection of the reactor internals revealed a long crack in a feed
water sparger. A joint analysis of the failure by the reactor owner, Northeast Utilities, and
the reactor manufacturer, General Electric, concluded that the problem was due to bypass
leakage. This conclusion gave rise to a proposed solution, which was implemented. But
one year later, during the next refueling outage, an inspection of the same feed water
sparger revealed even larger cracks. It turned out the cause of the cracking had not been
bypass leakage, but rather high-cycle metal fatigue, a diagnosis which lead to an entirely
different solution. Neither the plant owner nor the reactor vendor had diagnosed the true
cause of the cracking.

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Crystal River 3
During a steam generator replacement outage at Florida’s Crystal River Unit 3 nuclear
power plant, the nuclear power plant owner, at the time Progress Energy, cut a large hole
into the side of the 42-inch thick concrete containment building to install replacement
steam generators. The hole caused the containment to crack and delaminate. Following a
year of analysis, Progress Energy proposed a repair plan to the NRC, which was
implemented. However, the containment cracked and failed again one year later as the
repair was being implemented. The plant owner apparently failed to correctly calculate
the stress being applied to the containment structure. After four years of attempted
repairs, the Crystal River Unit 3 plant was abandoned and is now being decommissioned.
The financial losses to ratepayers during those four years of inadequate assessment and
implementation were massive, exceeding $300,000,000 in salaries and the loss of the
corporation’s $2 billion asset.
As Entergy pursues a rapid restart of Indian Point Unit 2, it is failing to consider the ultimate root
cause of the baffle-former bolt failure. Allowing the plant to restart before the ultimate root cause
of this real operating hazard is definitively uncovered is irresponsible from both a financial and a
risk perspective for the 20 million people living within 50 miles of these aged and deteriorating
reactors. Likewise, continued operation of Indian Point Unit 3 while its “sister” unit exhibits
severe damage is also irresponsible and an additional threat to public safety. Entergy should be
required to conduct an ultimate root cause analysis and conduct the necessary repairs of both
reactors before they are allowed to return to full operation.
Conclusion
As a result of New York State’s persistence, inspections were finally performed at Entergy’s
Indian Point Unit 2 in March 2016 that uncovered 227 critical baffle-former assembly bolts that
were either missing or broken. These inspections highlighted significant safety and reliability
shortfalls that led Indian Point Unit 2 to remain shut for the time being. More than a quarter of
the baffle-former assembly bolts, which are part of a critical safety system, are defective.
Almost two months after the Indian Point Unit 2 inspections, the cause of the broken and missing
bolts remains shrouded in confusion and uncertainty. Until the ultimate root cause is completely
understood, no effective repair can be accomplished. The magnitude of the problem and the

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significant safety ramifications makes it imperative that Unit 3, the exact replica of Unit 2, be
immediately shut down until an inspection to determine if there any flaws within the reactor.
Both reactors should remain shut down until an ultimate root cause analysis determines the cause
of any damage. Additionally, the repairs for such damage must be completed prior to any
thought of a possible restart.
The evidence reviewed by Fairewinds shows that the NRC should immediately implement five
actions to address the critical safety problems at the Indian Point Site, which lies in such close
proximity America’s largest and most vulnerable city. The actions that should be implemented
by the NRC are:
1. Close the loophole that allows Entergy to determine when and if Indian Point 2 restarts.
To close this loophole, it is imperative that the NRC Issue a Confirmatory Action Letter
(CAL) requiring the plant to remain closed until the NRC approves its restart following
an ultimate root cause evaluation that assesses the extent of the damage and delineates a
complete itemized recovery plan.
2. Mobilize a special Augmented Inspection Team (AIT) to assess the complications inside
the Indian Point 2 reactor.
3. Issue a Confirmatory Action Letter requiring the immediate shutdown and inspection
Indian Point Unit 3 in order to determine the amount of aging reactor damage within this
replica reactor.
4. If issues are found at Indian Point Unit 3, the NRC should mobilize a second Augmented
Inspection Team (AIT) to assess the complications inside Indian Point Unit 3’s reactor.
5. If issues are uncovered at Indian Point Unit 3, the CAL should require the plant to remain
shut, like Indian Point Unit 2, until such time the NRC approves restart following an
ultimate root cause evaluation that assesses the extent of the damage and delineates a
complete itemized recovery plan.